17.   Proposed text excludes the IBC requirements for structural tests and special inspections, except for joist hangers and roof tiles, due to belief that these requirements are substantially met by continuing Wisconsin's current construction oversight by registered professionals. [Comm 62.1700 (and Comm 61.50)]
18.   Three modifications developed by the Structural Review Council would improve inadequacies in the IBC. These modifications address piles and piers in subsiding areas [Comm 62.1807 (1), (2), and (5)], empirical design of masonry [Comm 62.2109], and moisture barriers for nondurable wood bearing on exterior masonry or concrete [Comm 62.2304].
19.   Several modifications provide alternative or minor additional plumbing requirements. These modifications address privacy and access to toilet rooms [Comm 62.1209], waiver of toilet rooms for unattended gasoline stations [Comm 62.1209 (2) (b)], maintenance of toilet rooms [Comm 62.2900 (1) and (2)], permanent and portable outdoor toilets [Comm 62.2900 (3)], enclosure of toilet fixtures [Comm 62.2900 (4)], substitution of urinals for water closets [Comm 62.2902 (1) (a)], cross-references to plumbing fixture requirements by other agencies [Comm 62. 2902 (1) (b) and (5)], lavatories for toilet rooms [Comm 62.2902 (3)], signage for toilet rooms [Comm 62.2902 (4)], remote toilet rooms for small retail stores [Comm 62.2902 (4)], and direct access to toilet rooms for customers in stores [Comm 62.2902 (6)].
20.   Three modifications are proposed for continuing Wisconsin's current practice of not applying or enforcing requirements for the design or installation of conveyors and personnel or material hoists. [Comm 62.3001]
21.   Proposed text requires that where ventilation openings are provided in hoistway walls, the openings must have guards securely fastened to the hoistway, to prevent creation of a shear point for maintenance and elevator inspectors. [Comm 62.3004 (1)]
22.   Floor drains, sumps, and sump pumps are permitted by the IBC in a hoistway shaft if they are directly connected to the storm or clear water drain system. Proposed text clarifies that a connection to a sanitary system is prohibited and that plumbing systems not used in connection with the operation of the elevator may not be located in the elevator equipment rooms. [Comm 62.3004 (2) and Comm 62.3006 (2)]
23.   Proposed text clarifies that where elevator machine rooms serve pressurized elevator hoistways and are not directly connected to the hoistway, the machine rooms are not required to be pressurized. [Comm 62.3006 (1)]
24.   Proposed text clarifies that buildings connected by pedestrian access structures are considered separate structures. [Comm 62.3104]
25.   Proposed text would continue Wisconsin's current practice of not regulating encroachments into a public right-of-way. [Comm 62.3200]
26.   Proposed text would continue Wisconsin's current practice of not regulating safeguards during private-sector construction, except for maintaining egress, preventing water accumulation, and protecting adjoining property. [Comm 62.3300]
27.   Three National Fire Protection Association standards that are adopted in the IBC are proposed to be replaced with more recent versions which are currently adopted in Wisconsin. [Comm 62.3500]
28.   Proposed text would continue Wisconsin's current practice of not regulating employee qualifications, boards of appeals, agricultural buildings, fire districts, supplemental barrier-free accessibility, rodent proofing, flood-resistant construction, signs, and patio covers. [Comm 62.3600]
Chapter Comm 63
The International Energy Conservation Code contains energy conservation requirements relating to the design of building envelopes for adequate thermal resistance and low air leakage, and the design and selection of mechanical, electrical, service water-heating and illumination systems and equipment, which will enable the effective use of energy in new and altered building construction. The IECC is divided into chapters that apply to low-rise residential buildings (<3 stories in height), and to commercial buildings, which includes high-rise residential buildings (4 stories or more in height), and non-residential buildings of any height.
The IECC is applied based on the occupancy classification of the building (residential or commercial) and how compliance with the energy conservation requirements will be demonstrated. The intent is that any of the options chosen will provide the same levels of energy conservation. The following is how the IECC is to be applied:
  Chapter 4, 5 or 6 of the IECC may be used for low-rise residential buildings.
  Chapter 7 or 8 of the IECC may be used for high-rise residential buildings and all commercial buildings.
IECC chapter 7 requires commercial buildings to comply with ASHRAE/EIS, Energy Code for Commercial and High-rise Residential Buildings. The existing chapter Comm 63 is basically the ASHRAE 90.1 Standard with various modifications and additions to improve energy conservation, and application and code enforcement. Therefore, the existing chapter Comm 63 with the improvements is substantially equivalent to chapter 7 of the IECC. It is proposed to maintain the existing Comm 63 requirements and locate them in subchapter III of the new proposed chapter Comm 63. Commercial buildings may be designed for compliance with the energy conservation requirements in chapter Comm 63, subchapter III as one option, or with the requirements in IECC chapter 8 as the other option. It is also the intent of these rule changes to ensure that either option chosen will result in equivalent energy conservation.
The following listing is a summary of the major concerns identified by the Department and the Energy Conservation Specialty Council relating to the use and application of the IECC and recommendations for changes and additions to or omissions from the IECC.
1.   In general, the IECC requirements are substantially equivalent to the energy conservation requirements specified in the existing chapter Comm 63 for commercial buildings. However, the IECC has more stringent energy conservation requirements for low-rise residential buildings, especially the building envelope requirements. To evaluate how the IECC requirements would impact the design of residential buildings, the Department performed a survey of current construction plans for residential buildings located throughout the state to see if the buildings complied with the stricter IECC requirements. The results showed that 90% of the new construction plans surveyed already met the stricter building envelope requirements and most designers and owners would not be affected adversely by using the IECC requirements. These changes are viewed as useful and beneficial to the owners of residential buildings.
2.   Approved vapor retarders are required on all frame walls, floor and ceilings, instead of permitting the option to ventilate these areas. This change is necessary for both infiltration and condensation control in Wisconsin's severe climate. [See sections Comm 63.0502, Comm 63.0802 (2), and Comm 63.1011 (4)]
3.   Floors over outdoor air are required to have the same U-values as floors over unheated spaces. The minimum levels of insulation in the IECC are not cost effective for the owner. All other insulation levels were determined to be cost effective using a life-cycle cost economics analysis. A review of residential plans received by the Department indicated that 90% of new construction already meets the IECC thermal envelope requirements. [Comm 63.0502]
4.   The heating load calculations are to be determined in accordance with the requirements in s. Comm 63.1023. Both Comm 63.1023 and IECC section 503.3.1 follow the ASHRAE Handbook of Fundamentals; however, Comm 63.1023 includes specific parameters for areas such as indoor and outdoor design conditions, envelope conditions and lighting loads not included in the ASHRAE Handbook. Comm 63.1023 provides better direction to the users in the application of the code. [Comm 63.0503 and Comm 63.1023]
5.   Interior design temperatures are to be maintained as specified in chapter Comm 64, Heating, Ventilating and Air Conditioning Code. [Comm 63.0003 (3)]
6.   Adjustments for local exterior design conditions are to be determined through local weather resources, including computer programs for equipment sizing. [Comm 63.0302 (1)]
7.   Pipe insulation for both commercial and residential buildings is to be provided in accordance with ASHRAE 90.1, Table 403.2.9.1. The new table for pipe insulation will be applied in all the options available for showing compliance with the energy conservation requirements. Table 63.1029 translates the inches of insulation required into R-values. This reduces the need for all parties involved from performing cumbersome calculations. [Comm Table 63.1029]
8.   Supply ducts located in the plenum and within the building envelope are to be insulated to R-4 in addition to the requirements for unconditioned areas and outdoor areas. Moisture damage to building materials may occur from condensation from uninsulated ducts within a plenum. There is little, if any, additional cost to go from uninsulated sheet metal material to an R-4 insulated duct material. [Comm 63.0503 (2) (b) and Comm 63.0803 (2) (e)]
9.   The IECC requires ducts in unconditioned areas to be insulated to R-5; however, the typically available R-5 ductwrap is only R-4.6 after it is installed in accordance with the manufacturer's instructions. This discrepancy has caused problems in the application and enforcement of the code. It is proposed to require ducts in these areas to be insulated to R-4. This requirement will be applicable in all options used to show compliance with the energy conservation requirements. [Comm 63.0503 (2) (b) and Comm 63.0803 (2) (e)]
10.   Recessed lighting installed in the building envelope must be sealed to reduce infiltration. [Comm 63.1011 (3), Comm 63.0602 (2), and Comm 63.0802 (4)]]
11.   Automatic dampers are required on all outdoor air intakes. The IECC allows gravity or automatic dampers to be used. Experience indicates that gravity dampers are opened by wind subjecting occupants to drafts and results in higher energy costs to owners. [Comm 63.0503 (2) (c) and Comm 63.0803 (2) (d) and (3) (b)]
12.   Light power budgets and controls requirements are to comply with Comm 63, subchapter III, Part 5, even if the IECC chapter 8 option is chosen. The lighting requirements in Comm 63 are in an improved format and provide for the most efficient use of lighting for energy conservation. [Comm 63.0504 (4) and Comm 63.0805]
13.   Owners of commercial buildings are given options for showing compliance with the energy conservation code. One option is to show compliance with ASHRAE 90.1. Since chapter Comm 63, subchapter III is essentially ASHRAE 90.1 with various amendments for improving energy conservation, application and enforcement, it is proposed to substitute language for IECC chapter 7 to require compliance with Comm 63. [Comm 63.0701]
14.   A modification was made to Table 63.1049 relating to interior lighting power allowances for merchandising display lighting. It is proposed to allow the smaller of the actual wattage of the lighting equipment for displays or a 0.8 W/ft2 times the floor area of the display area to be added to the interior lighting power. [Table 63.1049, Part b]
15.   In commercial buildings, each fan system is required to have economizer controls that comply with s. Comm 63.1031. The IECC does not provide for the most efficient use of that equipment and the owner would be missing opportunities to save energy and money. This requirement for the use of economizers will not be applied to low-rise residential buildings. [Comm 63.0803 (2) (c) and Comm 63.0803 (3) (b) and (d)]
16.   Currently, under chapter Comm 63 off-hour or set-back HVAC controls are required in both residential and commercial buildings. However, in the IECC off-hour controls are required only in commercial facilities. Since it was the goal the Department to stay as close as possible to the IECC requirements and limit Wisconsin based requirements, it was decided not to apply the off-hour controls to residential buildings.
17.   The IECC energy conserving requirements for residential pool water heaters will not be applied. They are inconsistent with requirements for commercial facilities, the on-off switch requirements are covered by other codes; the pool cover requirement is too vague to enforce and the need for a time switch to allow for lower time-of-day utility rates should be based on consumer economics. [Comm 63.0504 (3)]
(A more detailed comparison of the current and proposed requirements for chapter Comm 63 is available at the Safety and Buildings' web site at www.commerce.state.wi.us. or can be obtained from Roberta Ward at rward@commerce.state.wi.us or at 608/266-8741 and 608/264-8777, TTY.)
Chapter Comm 64
This rule revision, which repeals and recreates chapter Comm 64, relating to heating, ventilating and air conditioning, includes adoption of the 2000 International Mechanical Code ®, with various omissions, additions or substitutions.
The following listing is a summary of the major concerns identified by the Department and the HVAC Specialty Council relating to the use and application of the IMC and recommendations for changes and additions to or omissions from the IMC.
1.   The proposal is to continue to have the designer or installer provide the owner or operator with written instructions on the operation and maintenance of the equipment. The IMC is silent on this issue and experience proves that properly maintained equipment is less costly to operate and increases the life of the equipment. [See section Comm 64.0102]
2.   The IMC requires that all appliances be listed and labeled unless approved as a modification; the proposal is to retain the current provisions for approval of unlisted equipment. [Comm 64.0301]
3.   The proposal is to maintain the equipment testing and balancing provisions of the current code to assure proper operation of equipment. [Comm 64.0304 (1)]
4.   The proposal is to keep indoor design temperatures below 68oF for some occupancies as currently allowed. Current provisions allow spot heating, and waiving of heating requirements for seasonal occupancies. Such allowances are in recognition high costs of operation during the Wisconsin heating season. [Comm 64.0309]
5.   The proposal is to recognize that natural ventilation of some occupancies in Wisconsin may be ineffective and may thus compromise indoor air quality. Under the IMC, natural ventilation is allowed as an option in all spaces, except for: smoking lounges, toilet rooms, multifamily parking structures and public locker rooms. Current requirements for mechanical ventilation in many more occupancies are proposed to be maintained. [Comm 64.0401 (1)]
6.   The proposal maintains current requirements for required building exhaust ventilating systems to operate continuously when people are in the building. An option is also proposed to allow rooms with 2 or fewer toilet fixtures to be exhausted only when such rooms are occupied. The exhaust fan could then be interconnected with the light switch. [Comm 64.0401 (2)]
7.   The proposal also is to continue allowing current exceptions for reducing clearances for intake and exhaust openings that have been found to not compromise indoor air quality, but can reduce installation costs. [Comm 64.0401 (4)]
8.   This proposal is to allow an option to use an engineered system that will produce the same indoor air quality as following the outdoor air ventilation rates as prescribed in the code. [Comm 64.0403 (2)]
9.   A revised IMC Table 403.3 is proposed which includes the following: requires the same outdoor air requirements for similar occupancies; makes additional entries for common occupancies from the current Table Comm 64.05; reduces outside air to 7.5 cfm/person in most occupancies as under the current code; requires the use of AIA Guidelines for Hospitals and Nursing Home Occupancies; and garage ventilation is reduced from 1.5 cfm/sf to 0.5 cfm/sf of exhaust. [Table 64.0403]
10.   Some occupancy requirements are proposed to be maintained from the current code: natural ventilation may be used in smaller toilet rooms or janitor closets; and pool ventilation may be reduced with humidity control. [Comm 64.0403]
11.   The proposal does not adopt IMC 403.3.2 that requires the amount of outside air to be based on a complex set of room by room calculations. It is replaced with current provisions that allow the amount of outside air to be based on the total number of occupants served by the system, rather than separate calculations for each room. The minimum air change rate is also retained. This is necessary when the outside air is based on the total number of occupants served by the system. The proposal provides for the movement of 'cleaner' air from areas of low occupancy to those of high occupancy. The air movement also increases filter effectiveness. For VAV systems, a minimum movement is needed. [Comm 64.0403 (6)]
12.   Wisconsin experienced failure in automatic sensing devices installed in place of continuous exhaust in parking garages. The proposal includes additional provisions including the requirement to operate exhaust for at least five hours per day to assure effective exhaust results. [Comm 64.0404]
13.   The proposal is to delete the requirement for an exhaust system where contamination may be simply "irritating." The current code provision does not require a system to accommodate those individuals who may have high sensitivity to contaminants. Where contamination is injurious to health or safety, an exhaust system must be installed. [Comm 64.0502]
14.   The IMC has additional, more detailed requirements for commercial kitchen exhaust than the current chapter Comm 64. The proposal is to provide a performance requirement for alternatives to welded seams and joints which will provide more flexibility in installation and lower costs. [Comm 64.0500, Comm 64.0506, and Comm 64.0507]
15.   Another proposal relating to commercial kitchen exhaust is to require commercial kitchen fans for use in grease-laden air to be so listed. [Comm 64.0506]
16.   The proposal is to allow the reduction in the clearances between heaters and duct lining when the lining is so listed. [Comm 64.0604]
17.   The proposal adds a requirement for some healthcare facilities to comply with AIA (American Institute of Architects) guidelines for filtration. [Comm 64.0605]
18.   The definition of 'unusually tight construction' has been modified for chs. Comm 64 and 65 to reflect current Wisconsin building construction standards. In referencing this modification, the requirement for outside air for combustion has also been modified to allow greater use of inside air for combustion purposes (with restrictions). [Comm 64.0702]
19.   The IMC prohibits the use of unvented, permanently installed liquid- and solid-fueled equipment. As under the current code, both installed and portable unvented equipment is prohibited under the proposal. [Comm 64.0801]
20.   The proposal is to make the chapter internally consistent and consistent with the International Fuel Gas Code (IFGC), chapter Comm 65 for the following situations: location of combustion air openings, setback between intakes and exhausts and contaminant sources. [Comm 64.0710 and Comm 64.0918]
21.   The proposal substitutes chapter Comm 41 for IMC boiler and hydronic piping requirements. Only minor revisions are proposed for the IMC requirements for water heaters used in space heating systems. The IMC, unlike the current chapter Comm 64, does not limit the use of such water heaters to 100,000 Btu/hour input. [Comm 64.1001 and Comm 64.1201]
22.   The proposal substitutes chapter Comm 45 for IMC refrigeration requirements. [Comm 64.1101]
23.   The proposal does not include IMC fuel oil requirements; these requirements are contained in chapter Comm 10. [Comm 64.1301]
24.   The IBC requirements for fire resistive construction such as equipment enclosure, fire rated resistive damper placement, and air movement in rated corridors, may impact HVAC system design and installation.
25.   In addition to the AIA Standard R673, standards, either newer than that adopted in the IMC or not adopted in the IMC, are adopted; they are: NFPA 13-1999, Installation of Sprinkler Systems; and NFPA 54-1999, National Fuel Gas Code.
(A more detailed comparison of the 2000 IMC and IFGC, the current chapter Comm 64, and this proposal is available at http://www.commerce.state.wi.us/SB/SB-RuleChanges.html or can be obtained from Roberta Ward at rward@commerce.state.wi.us or at telephone 608/266-8741 and 608/264-8777, TTY.)
Chapter Comm 65
This rule revision, which creates chapter Comm 65, relating to Fuel Gas Appliances, includes adoption of the 2000 International Fuel Gas Code®, with various omissions, additions or substitutions.
The following listing is a summary of the major concerns identified by the Department and the HVAC Specialty Council relating to the use and application of the IFGC and recommendations for changes and additions to or omissions from the IFGC.
1.   Like the International Mechanical Code®, the IFGC requires that all appliances be listed and labeled unless approved as a modification. The proposal is to retain current code provisions which outline the Wisconsin process and the information and testing needed for this review. The IFGC is silent on what rule applies when the manufacturer's instructions may be in conflict with rule provisions. The proposal is to duplicate the provision in chapter Comm 64 and provide consistency for all fuel types. The IFGC is also silent on the clearances, guarding, appliance marking, and piping supports; the proposal is to duplicate the provisions proposed in chapter Comm 64. As in chapter Comm 64, a requirement for written instructions on operation and maintenance is proposed. [See sections Comm 65.0301 and 65.0304]
2.   Current Wisconsin provisions prohibit the use of unvented space heaters because of the tight construction of Wisconsin buildings; this prohibition is proposed for both chapters Comm 64 and 65. [Comm 65.0303 (2) and 65.0620]
3.   As in chapter Comm 64, the proposal is to retain current provisions that recognize Wisconsin's severe climate in that heat exchangers and burners must be made of corrosion resistant material. [Comm 65.0303 (1)]
4.   As in chapter Comm 64, the equipment testing and balancing provisions are proposed such that these two chapters will be consistent for all fuel types. [Comm 65.0305]
5.   The proposal is to continue some current Wisconsin provisions for use of indoor air for combustion in "tight" construction, consistent with provisions for other fuel types under chapter Comm 64. [Comm 65.0304]
6.   The 2000 IFGC does not include the various provisions previously contained in 1998 IMC with regard to combustion air; the proposal is to maintain these requirements and be consistent for all fuel types. [Comm 65.0304]
7.   The IFGC is also silent on various requirements for safe installation of combustion air ducts and outside air intake openings. The proposal is to duplicate these provisions from chapter Comm 64. [Comm 65.0304 and Comm 65.0620]
8.   The proposal is to be consistent with chapter Comm 64 and not require platforms for fan only installations. [Comm 65.0306]
9.   The current requirements for gas piping (using the NFPA 54 standard) are proposed to be retained. [Comm 65.0400]
10.   The proposal is to not allow the installation of a number of unvented appliances as under the current code. Products of combustion in buildings may cause concern for safety and health and structural damage. [Comm 65.0501]
11.   The proposal is to be consistent for all fuel types in termination of venting system and setback distances between outside air intakes and containment sources. [Comm 65.0503]
12.   The proposal is also consistent for all fuel types for requirements for suspended duct furnaces. [Comm 65.0609]
13.   Also, the American Institute of Architects (AIA), R673-1996-97, (Guidelines for Construction and Equipment of Hospital and Medical Facilities) as is used by DHFS is adopted in this chapter.
(A more detailed comparison of the 2000 IMC and IFGC, the current chapter Comm 64, and this proposal is available at http://www.commerce.state.wi.us/SB/SB-RuleChanges.html or can be obtained from Roberta Ward at rward@commerce.state.wi.us or at telephone 608/266-8741 and 608/264-8777, TTY.)
Chapter Comm 66
The Department has the responsibility to supervise every public building and place of employment, including the fire safety aspects, in order to protect the life, health, safety and welfare of every employee, frequenter, tenant and firefighter. The changes contained in this proposal, including adoption of the International Fire Code® (IFC), are intended to update code requirements and adopted national standards relating to building construction, building equipment, commodity storage and isolation, fire prevention, fire detection, and fire suppression as one part of that responsibility.
The IFC is divided into the following 45 chapters that cover fire safety hazards in the areas of general fire safety requirements, hazardous structures, hazardous operations and hazardous materials:
1.   Administration
2.   Definitions
3.   General Precautions Against Fire
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